Belgium publishes guidance on new CFC rules
Belgium’s tax authorities have issued two circular letters - Circular 2024/C/82 and Circular 2024/C/83 - on 13 December 2024 - providing clarity on specific aspects of the controlled foreign company (CFC) rules introduced in 2023. The amended
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Austria updates CFC rules to prevent double taxation under Pillar Two
Austria's parliament has amended its CFC rules to avoid double taxation issues under the Pillar Two global minimum tax framework. Amendments to Section 10a of the Austrian Corporate Income Tax Act have been approved and now require Qualified
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Czech Republic updates list of non-cooperative CFC jurisdictions
The Czech Republic Ministry of Finance has released Financial Bulletin No. 9/2024, containing a notice regarding the lists of non-cooperative jurisdictions for various periods about the Czech Republic's controlled foreign company (CFC)
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US: IRS clarifies CFC not eligible for dividends received deduction under section 245A
The US Internal Revenue Service (IRS) issued an Office of Chief Counsel memorandum clarifying that a controlled foreign corporation (CFC) is not eligible for a dividends received deduction under section 245A. This memorandum provides
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Chile updates tax compliance law, introduces changes to GAAR, transfer pricing, and CFC
Chile's Internal Revenue Service (SII) has announced that the Law on Compliance with Tax Obligations (Law No. 21.713) has been published in the Official Gazette on 24 October 2024. General and Special Anti-Avoidance Rules changes The General
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Latvia updates list of tax havens, removes Antigua and Barbuda
Latvia announced an updated list of low-tax and tax-free jurisdictions in the Official Gazette on 23 October 2024. This list, derived from the latest EU list of non-cooperative jurisdictions, notes the removal of Antigua and Barbuda, effective 1
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Taiwan introduces CFC De minimis rule for profit seeking enterprises
Taiwan's Ministry of Finance has announced a de minimis test enabling profit-seeking enterprises to avoid recognizing investment income under the CFC Rules on September 2024. The National Taxation Bureau of the Southern Area, Ministry of Finance
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Argentina removes five countries from non-cooperative jurisdictions list
Argentina has issued Decree 603/2024 of 10 July 2024, updating the list of non-cooperative jurisdictions for tax purposes as defined under Decree 862/2019. In this revised non-cooperative jurisdictions list, it removed Burkina Faso, Benin, Papua New
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Russia introduces tax reform draft laws
Russia's Ministry of Finance presented a set of draft laws to the Russian Government intended to enhance the tax system on 29 May, 2024. The package contains several major amendments to the Tax Code, Budget Code and Budget Law for 2024 and the
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Germany issues guidelines to combat tax havens
The German Ministry of Finance has released guidance on implementing the Tax Haven Defense Act, formerly the Act to Prevent Tax Avoidance and Unfair Tax Competition. This guidance introduces stringent measures to decrease business dealings with
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Czech Republic updates non-cooperative jurisdictions list for CFC rules
The Czech Republic Ministry of Finance issued the Financial Bulletin No. 3/2024, on 28 February, 2024, which contains an updated notice regarding the list of non-cooperative jurisdictions concerning the Czech Republic's Controlled Foreign Company
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Russia: MoF clarifies tax exemption for CFC amid treaty suspensions
The Guidance Letter No. 03-12-11/2/11449, published by the Russian Ministry of Finance (MoF) on 12 February, 2024, addresses the tax exemption applicable to profits of Controlled Foreign Companies (CFCs) situated in jurisdictions with which Russia
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Sweden considers new permanent residency rules for taxation
Sweden's Ministry of Finance announced, on 3 May, 2024, a significant update regarding permanent residency criteria for tax purposes. Following the release of a memorandum by the Tax Agency in November, 2023, proposing a redefinition of permanent
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Italy introduces CFC substitute tax measures
Italy’s Revenue Agency has published provisions for Controlled Foreign Company (CFC) substitute tax option, released as part of Legislative Decree No. 209 of 27 December 2023. Legislative Decree No. 209 outlines measures for adopting the Pillar
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Taiwan: Ministry of Finance relaxes taxation for CFC
The Ministry of Finance in Taiwan has released a notification regarding eased taxation regulations concerning profits from Controlled Foreign Corporations (CFCs) invested in enterprises situated in non-low-tax jurisdictions that are acknowledged
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Ukraine issues controlled foreign companies (CFC) notification requirements
On 28 March 2024, the State Tax Service of Ukraine released a notice directed to companies and individuals residing in Ukraine, detailing their duty to report on controlled foreign companies. This notification outlines the requirement for
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Sweden: MoF proposes updates to pillar 2 global minimum tax rules
On 19 March 2024, the Swedish Ministry of Finance (MoF) released proposed amendments to the Act on Additional Tax, aimed at incorporating the Pillar 2 global minimum tax as outlined in Council Directive (EU) 2022/2523. As per the proposal, a
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Japan submits tax reform bill 2024 to parliament
On 2 February 2024, the Japanese Cabinet submitted the tax reform bill 2024 to parliament. The bill covers various tax measures. Key measures of the bill include: Driving Domestic Growth: The introduction of new tax credit incentives is
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